Resource Sector Taxation, Taxnet Pro

determine whether the mine had previously come into production in reasonable commercial quantities, thus determining whether the expenses to be renounced could qualify as Canadian exploration expenses. Second, the ruling approved a novel cross-border structure in which the non-resident issuer of the flow-through shares could renounce expenditures that were renounced to it via a back-to-back issuance of flow-through shares by its Canadian subsidiary that owned the mine.